Issue and Options 2023
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New searchAs indicated in response to question Q-B6, the Cotswolds National Landscape Board considers that the Cotswolds National Landscape should be a priority area for delivering nature recovery.
Q-B1. Please select the option which is most appropriate for South Warwickshire Option B1a. The Cotswolds National Landscape Board supports the principle of helping to protect areas of land that help to preserve the structure and character of settlements. This principle is an important consideration in the Cotswolds National Landscape. For example, the Board’s ‘Cotswolds AONB Landscape Strategy and Guidelines’ identify the following ‘landscape implication’ relating to the development, expansion and infilling of settlements:43 . Interruption, weakening or loss of the historic character of settlements and the historic context in how they have expanded, especially the importance of the relationship between the historic core of the settlement and surviving historic features such as churchyards, manor houses, burgage plots, historic farms, pre-enclosure paddocks and closes. One of the guidelines for addressing this issue is to: . Avoid proposals that result in the loss of archaeological and historical features or that impact on the relationship of the settlement and its links with surviving historical features. The Area of Restraint policy would potentially help to address this issue. Q-B3. Please select the option which is most appropriate for South Warwickshire The Cotswolds National Landscape Board supports the Special Landscape Areas (SLA) policy as it helps to protect these high-quality landscapes, including their associated historic and cultural features, by resisting development proposals that would have a harmful effect on their distinctive character and appearance. In the context of the Cotswolds National Landscape, SLAs are a useful as a mechanism for helping to protect the setting of the National Landscape (where the SLAs are adjacent to the National Landscape). To ensure that a consistent approach is taken across the whole of the Plan area, it would make sense to introduce SLAs within Warwick District, assuming that there are landscapes in Warwick District that merit SLA status. Q-B4. Please select the option which is most appropriate for South Warwickshire Option B4b. We agree with the following statement in the Issues and Options consultation document: . When considering development in and around the Cotswold National Landscape, regard should be given to conserving and enhancing the natural beauty of the area. In particular, great weight should be given to conserving and enhancing the landscape and scenic beauty, including its ‘special qualities’. Case law has clarified that great weight should be given to the impacts that development outside an Area of Outstanding Natural Beaty (AONB) might have on the natural beauty of the AONB. This includes visual impacts (i.e., impacts on views from the AONB) as well as impacts on dark skies (e.g., increases in light pollution resulting in ‘sky glow’) and tranquillity (e.g., increases in traffic flows through – and along the boundary of the AONB). Further information on this issue is provided in the Board’s position statement on ‘Development in the Setting of the Cotswolds AONB’.44 In addition, national planning policy requires that development within the setting of an AONB should be sensitively located and designed to avoid or minimise adverse impacts on the AONB.45 The inclusion of a buffer zone around the periphery of the Cotswolds National Landscape, within the Local Plan, would help to ensure that this issue is adequately addressed. For example, for particular types and / or scales of development within this buffer zone, the local planning authority (LPA) development management system should be set up to automatically: (i) identify that potential impacts on the National Landscape should be taken into consideration; and (ii) consult the Cotswolds National Landscape Board. Appendix 2 of this document provides the Board’s suggested consultation thresholds within: (i) the Cotswolds National Landscape; (ii) the setting of the Cotswolds National Landscape. For development management purposes, we would suggest applying a 3km buffer zone. It is important to note that, for individual development management proposals, the case officer should be at liberty to take account of AONB considerations and to consult the Cotswolds National Landscape Board for proposals that are further than 3km from the Cotswolds National Landscape boundary. This would potentially be the case for large urban extensions, new settlements or large-scale wind turbines, for example. However, the benefit of applying a buffer zone is that this would be a more automated process within the buffer zone. It probably wouldn’t be appropriate to automatically class the buffer zone a Special Landscape Area (SLA). This is because the landscape within the buffer zone might not meet the SLA criteria / thresholds. The buffer zone would primarily be a development management tool for taking AONB considerations into account – it would not automatically infer that the landscape within buffer zone was of a particularly high quality. 44 Cotswolds National Landscape Board (2016) Development in the Setting of the Cotswolds AONB. 45 Ministry of Housing Communities & Local Government (2021) National Planning Policy Framework. Q-B5. Please select the option which is most appropriate for South Warwickshire Option B5b. The Cotswolds National Landscape Board supports the principle that development should deliver environmental net gain. However, we are not convinced that an integrated approach is appropriate at this stage, especially given that the practical application of environmental net gain is still in its infancy (except for biodiversity net gain). One of the risks of an integrated environmental net gain approach is that it could be used a means of trading off a gain in one ecosystem service against a deficit in a different ecosystem service. A more appropriate way forward may be to explore environmental net gain through separate policies. By utilising appropriate ‘indicators’ for each of these policies in the Local Plan it may be possible to assess the state of each ecosystem service. If these indicators are reviewed collectively this would provide an overall indication of the extent to which environmental net-gain has been delivered in the Local Plan area over the lifetime of the Local Plan period (reviewed on an annual basis, or other appropriate timescale). When considering the issue of environmental net gain, it is vitally important to follow the mitigation hierarchy, doing everything possible to first avoid harm and then minimise adverse impacts. Compensation for losses should only come into play as a last resort. As with biodiversity net gain (in relation to international and national nature conservation designations and irreplaceable habitat), there may be some ecosystem service features that are too important to be included within an environmental net gain methodology. Q-B6. Should the South Warwickshire Local Plan introduce Wildbelt designations? Don’t know. The aspiration of the Wildbelt designation concept is to aid nature recovery. However, there are already mandatory processes in place to facilitate nature recovery. For example, the Environment Act 2021 established a new mandatory system of spatial strategies for nature recovery – Local Nature Recovery Strategies (LNRS). LNRS are designed as tools to encourage more coordinated practical and focused action and investment in nature. They are intended to help map a nature recovery network, locally and nationally. Rather than creating any additional designation ‘layer’ of Wildbelts, we consider that it would probably be more appropriate for the Local Plan to explicitly focus on delivering the aspirations of the LNRS and to focus nature recovery in the areas that would form the nature recovery network. We recommend that the LNRS and any resulting nature recovery plan / map should become part of the Local Plan / development plan. The Government has identified that protected landscapes, including Areas of Outstanding Natural Beauty (AONBs) such as the Cotswolds National Landscape, are an important component of its aspirations to ensure that 30% of land is managed for nature by 2030.46 In addition, the Government-commissioned Landscapes Review has proposed that protected landscapes should form the backbone of nature recovery networks.47 Therefore, we recommend that the Local Plan should explicitly identify the Cotswolds National Landscape as a priority area of nature recovery. The Local Plan should also explicitly have regard to the Cotswolds Nature Recovery Plan 48 46 https://www.gov.uk/government/publications/landscapes-review-national-parks-and-aonbs-government-response/landscapes-review-national-parks-and-aonbs-government-response 47 Defra (2019) Landscapes Review Final Report. Proposal 4. 48 Cotswolds National Landscape Board (2021) Cotswolds Nature Recovery Plan. Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites. Yes. The Local Plan could avoid simply duplicating national policy by identifying the relevant sites, habitats and species. National planning policy states that plans should distinguish between the hierarchy of international, national and locally designated sites.49 As such, the Local Plan policy should have different policy wording for each level of designation as the level of protection afforded to each level will be different. However, the importance of locally designated sites should not be underestimated. They constitute a vitally important component of our current ecological network and will play a vitally important role in delivering nature recovery. The Local Plan policy should address irreplaceable habitats. National planning policy lists several habitats that are considered to be irreplaceable.50 However, this list is not exhaustive. We recommend that, in addition to the irreplaceable habitats listed in the National Planning Policy Framework (NPPF), the Local Plan should also explicitly identify the following habitats as being irreplaceable: . Unimproved grassland that has been in-situ since before 1945. . Hedgerows that have been in-situ since before the Enclosure Acts. 49 Ministry of Housing, Communities and Local Government (2021) National Planning Policy Framework. Paragraph 175. 50 Ministry of Housing, Communities and Local Government (2021) National Planning Policy Framework. Annex 2: Glossary. Q-B10: Please add any comments you wish to make about a biodiverse and environmentally resilient South Warwickshire. In addition to our responses to questions Q-B1 to QB-10, please also have regard to our response to questions Q-C9.1, relating to biodiversity net gain.
